GFLI Antitrust Compliance Policy
It is the policy and practice of Global Feed LCA Institute (GFLI) to conduct all of its meetings and activities in strict compliance with applicable laws. Because GFLI members may be competitors, it is particularly important to comply fully with applicable antitrust and competition laws in the United States and countries where GFLI members operate. These laws seek to preserve and promote competition and to deter anticompetitive conduct.
GFLI is committed both to strict compliance with the antitrust and competition laws and to the avoidance of any appearance of improper or anticompetitive conduct. All meetings of the Board of Directors and the Officers, as well as committee meetings that might give rise to competitive concerns, will be monitored by trained GFLI staff (here-in-after to include employed staff and contracted staff) or outside counsel. To avoid subject matter or discussions which might be construed as anticompetitive, meeting agendas and minutes will be reviewed by counsel. GFLI has retained counsel to assist in addressing antitrust questions, if any, which may arise.
Violations of the antitrust and competition laws can result in heavy penalties for both companies and individuals. These penalties include treble damage awards, heavy fines, and injunctions. Individuals may be subject to criminal prosecution. It is therefore incumbent upon everyone participating in GFLI activities to avoid subject areas and discussions which might be construed as anticompetitive.
Individuals who participate in GFLI activities should read and abide by the following rules:
- There should be no discussion of prices, one’s own or those of a competitor, or of any factors which might affect prices such as discounts, margins, or sales terms.
- There should be no discussions regarding allocations of territories, markets or customers.
- GFLI will not develop standards or practices which restrict the business of any firm or individual.
- Individuals will not engage in discussion or conduct at social events incidental to GFLI meetings, which would not be proper at the meetings themselves.
- If any subject with any anticompetitive implication or appearance is raised at any GFLI meeting, persons attending the meeting should object immediately to a GFLI staff person and request that the subject be dropped.
- No GFLI sponsored meeting will begin until its agenda has been reviewed by trained GFLI staff or by counsel.
- 7Minutes of each GFLI meeting and committee meeting shall be reviewed and approved by trained GFLI staff or by counsel.
- Speakers at GFLI meetings shall comply with these guidelines. Where a speaker who is a member of GFLI or affiliated with a member of GFLI intends to address a topic dealing with economics, business practices, or product or service standards, a prepared text of the speaker’s presentation shall be reviewed by trained GFLI staff or counsel in advance of the meeting. If there is no prepared text, the speaker will provide an outline of the presentation and will discuss with GFLI staff or counsel how that outline will be developed.
- Any of GFLI’s statistical data collection and reporting programs will relate only to past transactions, and data will be reported in an aggregate form that does not permit identification of individual transactions or reporting companies. Membership participation in such programs is always voluntary. 1
- Criteria for membership are set forth clearly in the GFLI bylaws. No one will be denied membership except in accordance with the bylaws.
- Except for the obligation to comply with GFLI’s antitrust guidelines and rules, there shall be no agreement to adhere to any GFLI standard, guideline or rule. Each association member shall be free to follow or reject any GFLI standard, guideline, rule, or policy, as it sees fit. page 2 / 2 A fundamental purpose of GFLI’s activities is to improve competition and to facilitate competitive marketing. Adherence to these guidelines will facilitate that purpose.
It is the policy of the Global Feed LCA Institute (GFLI) that all information about GFLI’s anticipated activities revealed during presentations or discussions at meetings of GFLI’s Board of Directors, Officers, and other committees and task forces is regarded as confidential, not to be revealed outside of each attendee’s own organization or company before action has been taken and publicly announced by GFLI.
Meeting attendees (or others from an attendee’s company or organization) may discuss such matters with government representatives, other organizations, or other GFLI members to the extent expressly agreed to during the meeting. Otherwise, attendees may not discuss or disseminate any such information outside of their own organizations or companies, including but not limited to dissemination to their customers, clients, members, or others. Violation of this policy may result in exclusion from future meetings.